The Fourth Circuit Court of Appeals has issued a significant ruling regarding the treatment of pregnant inmates, specifically addressing the shackling of Tracey Edwards during her labor and postpartum period. The court's decision, issued on September 10, 2026, affects not only Edwards but also sets a precedent for how correctional facilities handle the treatment of pregnant women in custody. This ruling comes in the wake of increasing scrutiny over the treatment of incarcerated individuals, particularly those who are pregnant.
Tracey Edwards was incarcerated at the North Carolina Correctional Institution for Women (NCCIW) when she discovered she was pregnant. Edwards, who has a history of opioid use disorder (OUD), was eligible for medication-assisted treatment while pregnant. However, after giving birth, she was denied continued access to this treatment. Edwards filed a lawsuit against several prison officials, claiming violations of her Eighth Amendment rights and discrimination under the Americans with Disabilities Act (ADA) and the Rehabilitation Act.
The case arose after Edwards was shackled during her labor and delivery, despite internal policies at NCCIW that were supposed to protect pregnant inmates from such treatment. The district court ruled in favor of the defendants, granting them summary judgment on all claims. Edwards appealed the decision, leading to the current ruling from the Fourth Circuit.
In the ruling, the Fourth Circuit affirmed in part and vacated in part the district court's decision, sending the case back for further proceedings. The court highlighted the serious implications of shackling pregnant inmates, noting that the practice poses significant risks to both the mother and child. The court stated, "The shackling of pregnant offenders is controversial and dangerous," citing expert opinions that emphasize the harm caused by restraints during labor.
The court's opinion, authored by Judge DeAndrea Gist Benjamin, emphasized that shackling a pregnant inmate during labor and postpartum recovery is a violation of the Eighth Amendment. The ruling noted that the district court had granted qualified immunity to the defendants, but the Fourth Circuit found that the right to be free from such shackling was clearly established. The court pointed out that other circuits have condemned the practice, reinforcing the notion that pregnant women should not be subjected to restraints that could jeopardize their health and safety.
The Fourth Circuit's ruling is significant as it underscores the need for correctional facilities to adhere to humane treatment standards for pregnant inmates. The decision may lead to changes in policies regarding the shackling of pregnant women in custody, as well as the provision of medical treatment for opioid use disorder after childbirth. This case also highlights the ongoing discussions around the treatment of incarcerated individuals and the importance of ensuring their rights are protected.
Moving forward, the ruling may have broader implications for correctional facilities across the country, particularly as more states enact legislation to limit the shackling of pregnant inmates. The Fourth Circuit's decision reinforces the need for facilities to comply with established guidelines that prioritize the health and safety of both mothers and their children.
As for what’s next, the case has been remanded to the district court for further proceedings. Edwards and her legal team may seek to address the issues raised by the Fourth Circuit's ruling, and the defendants may have the opportunity to respond to the court's findings. There is also the possibility that the case could be appealed further, depending on the outcomes of the forthcoming proceedings.